Case 3:14-cr-00240-MPS Document 11 Filed 12/12/14 Page 1 of 2
LiNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA
-v.JEFFREY WARGA,
crim No -3 ,
t\håqÒ
VIOLATION:
18 U.S.C. $ 1349
P(
/5
(Conspiracy to commit wire fraud)
Defendant
INFORMATION
The United States Attorney charges:
COUNT ONE
(Conspiracy to commit wire fraud)
1.
At all
times relevant to this Information, the defendant JEFFREY WARGA
("WARGA") resided in Rhode Island and was the president and owner of Bay Components,
LLC.
2.
Fròm approximately July 2005 until November 2008, Bay Components, LLC was
a company located in Rhode Island that made material misrepresentations about parts
its
customers, and, among other things, sold counterfeit electronic parts
to a
it sold to
Connecticut
company ("CT Company").
3.
From approximately July 2005 until November 2008,
Connecticut and elsewhere,
'WARGA,
in the District of
and others known and unknown, did knowingly and
willfully conspire, combine, confederate, and
agree together
to devise a scheme and artifice to
defraud CT Company, and to obtain money and property by means of materially false and
fraudulent pretenses, representations and promises, and by material omissions, namely, V/ARGA
and his co-conspirators knowingly did transmit and cause to be transmitted by means of wire
communication in interstate and foreign commerce a writing, sign, signal, picture, or sound for
the purpose of executing such scheme and artif,rce, contrary to Title 18, United States Code,
Case 3:14-cr-00240-MPS Document 11 Filed 12/12/14 Page 2 of 2
Section 1343.
4.
It was aparL and an object of the conspiracy that V/ARGA, and others known and
unknown, willfully and knowingly engaged in a scheme and artifice to defraud their business
customers by means of materially false and fraudulent representations, including among other
things by falsely representing to customers, including CT Company, that the electronic parts
V/ARGA and his co-conspirators sold:
a.
were not from Asia when, in fact, V/ARGA and his co-conspirators knew the
parts had been purchased from companies located in Asia;
b.
were new parts from the original manufacturet, when, in fact, WARGA and
his co-conspirators knew the parts were used; and
c. were authentic parts when, in fact, V/ARGA
and his co-conspirators knew the
parts were counterfeit parts.
5.
It was apart and an object of the conspiracy that V/ARGA and others, known and
unknown, sent e-mails from V/ARGA's email account in Rhode Island to CT Company's email
account in Connecticut.
All in violation of Title
18, United States Code, Section 1349.
UNITED STATES OF AMERICA
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UNITED STATES ATTORNEY
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CE M. DUFFY
ASSISTANT UNITED
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TTORNEY